Doing Business With Iran: Mitigating Risk Exposure Under Canada s Economic Sanctions, Export Controls and Anti-Corruption Regimes
|
|
- Eugenia Curtis
- 7 years ago
- Views:
Transcription
1 Doing Business With Iran: Mitigating Risk Exposure Under Canada s Economic Sanctions, Export Controls and Anti-Corruption Regimes John W. Boscariol February 23, 2016
2 Why This Now Matters to Canadian Companies 2 the Canadian trade controls regime operating in the shadow of the United States increased penalties, enforcement by U.S. authorities pressure from U.S. affiliates, suppliers and customers (and U.S. government) Canada s reputation as an emerging sanctions hawk? penalty, operational, reputational exposure financings, banking relationships, joint ventures, private equity investments, mergers and acquisitions, going public transactions Canadian companies are now more concerned than ever before about whom they deal with, where their products and technology end up, and who uses their services
3 3 What Are Canada s Trade Controls? economic sanctions Special Economic Measures Act United Nations Act Freezing Assets of Corrupt Foreign Officials Act Criminal Code export and technology transfer controls Export and Import Permits Act Export Control List Area Control List domestic industrial security Defence Production Act, Controlled Goods Program other legislation of potential concern blocking orders (Cuba) anti-boycott policy and discriminatory business practices laws anti-bribery law (Corruption of Foreign Public Officials Act)
4 Who Administers and Enforces Canada s Trade Controls? 4 Global Affairs Canada Export Controls Division (export controls) Economic Law Section (economic sanctions) Canada Border Services Agency export reporting and enforcement at the border ensuring compliance with export controls and economic sanctions can detain and seize your goods Royal Canadian Mounted Police
5 5 Today s Focus new opportunities and risks in doing business with Iran economic sanctions export and technology transfer controls anti-corruption law
6 Economic Sanctions: Iran 6 starting in 2010, escalating Special Economic Measures Act measures against Iran culminating in broad trade embargo (May 29, 2013): included prohibitions against exporting, selling, supplying or shipping goods, wherever situated, to Iran, to a person in Iran, or to a person for the purposes of a business carried on in or operated from Iran importing, purchasing, acquiring, shipping or transhipping any goods that are exported, supplied or shipped from Iran, whether the goods originated in Iran or elsewhere making an investment in an entity in Iran providing or acquiring financial services to, from or for benefit of a person in Iran over 600 entities and individuals had been designated under Canada s Special Economic Measures (Iran) Regulations
7 Economic Sanctions: Iran 7 effective February 5, 2016, broad trade embargo measures have been removed, leaving only: SEMA prohibitions on activities involving 202 listed persons SEMA prohibitions on supplying any Schedule 2 items and related technical data United Nations restrictions export and technology transfer controls
8 Economic Sanctions: Iran 8 prohibitions against dealings with listed persons it is prohibited for any person in Canada or any Canadian outside Canada to (a) deal in any property, wherever situated, that is owned, held or controlled by a listed person or by a person acting on behalf of a listed person; (b) enter into or facilitate any transaction related to a dealing referred to in paragraph (a); (c) provide any financial or related service in respect of a dealing referred to in paragraph (a); (d) make any goods, wherever situated, available to a listed person or to a person acting on behalf of a listed person; or (e) provide any financial or related service to a listed person or to a person acting for the benefit of a listed person.
9 Economic Sanctions: Iran 9 prohibitions on supplying Schedule 2 items and technology it is prohibited for any person in Canada or any Canadian outside Canada to export, sell, supply or ship any of the goods listed in Schedule 2, wherever situated, to Iran, to a person in Iran, or to a person for the purposes of a business carried on in or operated from Iran it is prohibited for any person in Canada or any Canadian outside Canada to transfer, provide or disclose to Iran or any person in Iran any technical data related to the goods listed in Schedule 2 Schedule 2 has 41 categories, including: aluminum and aluminum alloy products - piping, tubing, fittings, flanges, forging, castings, valves, any unfinished products in any form and any waste or scrap that are made of aluminum and its alloys that are not specified in the Export Control List stainless steel valves, piping, tubing and fittings - any valves, piping, tubing and fittings that are made of stainless steel type 304, 316 or 317 and that are not specified in the Export Control List
10 Economic Sanctions: Iran 10 prohibitions against facilitating a violation: it is prohibited for any person in Canada or any Canadian outside Canada to do anything that causes, facilitates or assists in, or is intended to cause, facilitate or assist in, any act or thing prohibited by sections 3 or 4 [prohibitions on dealings with listed persons and prohibited items] requirement to report to RCMP or CSIS: every person in Canada and every Canadian outside Canada must disclose without delay to the Commissioner of the Royal Canadian Mounted Police or to the Director of the Canadian Security Intelligence Service (a) the existence of property in their possession or control that they have reason to believe is owned, held or controlled by or on behalf of a listed person; and (b) any information about a transaction or proposed transaction in respect of property referred to in paragraph (a)
11 Economic Sanctions: Iran 11 Canada s United Nations Act Iran regulations amended in accordance with UN Security Council Resolution 2231 list of designated persons (and regular reporting for FS firms) very long list of prohibited goods and technology prohibitions on provision of property and financial services in connection with prohibited items uranium mining restrictions shipping and aircraft restrictions sourcing ban on arms and related materials prohibitions against facilitation
12 Export Controls: Iran export and technology transfer controls under Export and Import Permits Act Notice to Exporters No. 196 (Feb 5, 2016): policy of denial for transfer of certain Export Control List items: certain Group 1 dual-use (cybersecurity, sensors, special materials, aerospace and propulsion, etc.) all Group 2 (munitions), Groups 3 and 4 (nuclear) certain Group 5 (strategic items) all Group 6 (missile technology, GPS) certain Group 7 (chemical weapons materials, containment facilities, human toxins) exceptions for items for civil aircraft 12
13 13 Export Controls on US-Origin Items: Iran ECL item 5400 covers US-origin goods and technology not elsewhere specified on ECL designed to ensure Canada is not used as a diversionary route to circumvent U.S. embargoes a permit is required for the transfer of all US-origin goods and technology from Canada to all destinations (excluding US) excludes goods that have been further processed or manufactured outside of the United States so as to result in a substantial change in value, form or use of the goods or in the production of new goods 50% rule of thumb used to be applied
14 14 Export Controls on US-Origin Items: Iran available General Export Permit No. 12 allows for export of US-origin goods and technology to all destinations except Iran (and Belarus, Cuba, North Korea, Syria) no written ECD policy for granting permits for export of US-origin goods or technology to these countries
15 15 Export Controls on US-Origin Items: Iran in the past, ECD has issued permits for US-origin goods to be shipped to Cuba (or Iran) in three circumstances: a US re-export licence has been obtained or humanitarian purposes (for the basic necessities of human life ) or in support of a previously permitted export or Canadian operations even if you determine that a permit is not required or if you obtain a permit, still must consider US law
16 Key Issues to Address in Your Iran Dealings 16 screening against listed and designated individuals and entities screen if any involvement in the transaction purchaser, ultimate user, vendor, creditor, borrower, broker, service provider applies regardless of where Canadian company is doing business include principals, directors, senior officers, entities and individuals who own or control Canada s lists differ from those of EU, US over 2,000 individuals and entities are listed in Canada s economic sanctions and anti-terrorism regulations
17 Key Issues to Address in Your Iran Dealings 17 review of all goods and technology to be supplied, sourced, transferred, exchanged screen against SEMA list screen against UN lists confirm no export controlled items technology transfer includes s, server uploads and downloads, server access from abroad, telephone discussions, training, tech support
18 Key Issues to Address in Your Iran Dealings new disconnect between US and Canadian sanctions against Iran re-exports/re-transfers of US-origin items to Iran US takes jurisdiction with as little as 10% US-origin differs from ECL 5400 test applied by Canadian authorities Iranian visitors / temporary resident employees access to US technology are you US-owned or controlled? OFAC General License H authorizes certain transactions for US-owned foreign entities involvement of US persons use of recusals other US touchpoints 18
19 Ongoing Challenges in Administration of Canadian Economic Sanctions 19 significant differences vs United States in administration and guidance on economic sanctions no FAQs, guidelines, rulings, opinions no consolidated lists for SEMA no voluntary disclosure process no deferred or non-prosecution agreements reporting obligations mandatory for property of designated or listed persons when Global Affairs Canada becomes aware of potential violation, immediate notification to RCMP
20 Anti-Corruption Law Compliance 20 Iran as high risk jurisdiction for corruption Corruption of Foreign Public Officials Act prohibits direct and indirect bribery of foreign government officials, including employees of state-owned or controlled entities benefits of any kind over 35 ongoing investigations by RCMP
21 Anti-Corruption Law Compliance 21 dealings with third parties screening contracts monitoring potential application of other anti-bribery laws US Foreign Corrupt Practices Act UK Bribery Act local (Iranian) law
22 Key Elements of Trade Controls and Anti- Corruption Compliance Programs 22 basic components of your compliance program should include: corporate compliance manual screens and lists third party due diligence, certifications appointment of compliance officers internal audit procedures whistleblower reporting and voluntary disclosure process training programs contracts written evidence of ongoing implementation
23 John W. Boscariol McCarthy Tétrault LLP International Trade and Investment Law Direct Line: LinkedIn: Twitter:
Best Practices in Export Compliance: Five Key Issues in Canadian Trade Control Compliance and Enforcement
Best Practices in Export Compliance: Five Key Issues in Canadian Trade Control Compliance and Enforcement Canadian Association of Importers and Exporters Webinar John W. Boscariol July 16, 2013 Today s
More informationManaging the Relationship Between Canadian and U.S. Export Controls and Economic Sanctions: Compliance and Enforcement Issues
Managing the Relationship Between Canadian and U.S. Export Controls and Economic Sanctions: Compliance and Enforcement Issues John W. Boscariol jboscariol@mccarthy.ca May 6, 2014 Export Compliance Training
More informationManaging the Relationship Between Canadian and U.S. Export Controls and Trade Embargoes
Managing the Relationship Between Canadian and U.S. Export Controls and Trade Embargoes John W. Boscariol jboscariol@mccarthy.ca May 7, 2013 Export Compliance Training Institute U.S. Export Controls on
More informationEnterprise Terrorist Financing & Money Laundering Policy
Policy Sponsor: Summary: CA and Compliance Sets out obligations under and suggestions for procedures to comply with antiterrorist financing, anti-money laundering and other laws implementing sanctions
More informationHarvard Export Control Compliance Policy Statement
Harvard Export Control Compliance Policy Statement Harvard University investigators engage in a broad range of innovative and important research both in the United States and overseas. These activities
More informationProtecting the Value of Your Transaction y
International Trade Due Diligence: Protecting the Value of Your Transaction y by Megan A. Gajewski, Susan M.C. Kovarovics, Michael D. Mellen and Christina A. Zanette You just closed a deal for your client,
More informationThis Policy supersedes the Terex Corporation Policy on Transactions in Iran, dated June 7, 2013.
TEREX CORPORATION POLICY REGARDING TRANSACTIONS IN IRAN (the Policy ) applies to all Terex operations and Terex team members worldwide. This Policy supersedes the Terex Corporation Policy on Transactions
More informationSecond Annual Impact of Export Controls on Higher Education & Scientific Institutions
The following presentation was presented at the Second Annual Impact of Export Controls on Higher Education & Scientific Institutions Hosted by Georgia Institute of Technology In cooperation with Association
More informationCOMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls
Westlaw Journal COMPUTER & INTERNET Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 31, ISSUE 1 / JUNE 13, 2013 Expert Analysis Software Development and U.S. Export Controls
More informationGOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY
GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY Goodman Global Group, Inc. and our affiliates (collectively, the Company ) are committed to complying with all laws applicable
More informationBEST PRACTICES PAPER SHARING AMONG DOMESTIC COMPETENT AUTHORITIES INFORMATION RELATED TO THE FINANCING OF PROLIFERATION
BEST PRACTICES PAPER SHARING AMONG DOMESTIC COMPETENT AUTHORITIES INFORMATION RELATED TO THE FINANCING OF PROLIFERATION February 2012 FINANCIAL ACTION TASK FORCE The Financial Action Task Force (FATF)
More informationANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY THIS POLICY DOES NOT CREATE A CONTRACT OF EMPLOYMENT OR ALTER THE AT WILL NATURE OF ANY EMPLOYEE S EMPLOYMENT IN ANY WAY. 1. Statement of
More informationUnited States Sanctions: General Considerations for Minority Investment
United States Sanctions: General Considerations for Minority Investment BY BEHNAM DAYANIM & CAROLYN MORRIS This Stay Current provides a general overview of considerations and parameters for US minority
More informationU.S. Foreign Corrupt Practices Act for Beginners
U.S. Foreign Corrupt Practices Act for Beginners This presentation, related materials and subsequent discussion are provided for educational purposes only. They do not constitute legal advice nor do they
More informationSummary of the North Korea Sanctions and Policy Enhancement Act of 2016
Summary of the North Korea Sanctions and Policy Enhancement Act of 2016 February 18, 2016 Less than a week after North Korea s January 6, 2016 nuclear test, the U.S. House of Representatives passed a sanctions
More informationCLOUD COMPUTING, EXPORT CONTROLS AND SANCTIONS. By Richard Tauwhare, Dechert LLP i
CLOUD COMPUTING, EXPORT CONTROLS AND SANCTIONS By Richard Tauwhare, Dechert LLP i This is a summary of an article originally published in the August 2015 edition of The Journal of Internet Law and is reprinted
More informationU.S. Economic Sanctions Laws and How They Affect Insurance Brokers
U.S. Economic Sanctions Laws and How They Affect Insurance Brokers The United States Government imposes economic sanctions against several countries and a large number of individuals and entities, in response
More informationManaging Third Party Risks in a Global Supply Chain
Managing Third Party Risks in a Global Supply Chain The Companies You Keep William Marshall, Hong Kong Ross Denton, London Jasper Helder, Amsterdam Baker & McKenzie Amsterdam N.V. is a member firm of Baker
More informationTRADE CONTROL POLICY FEBRUARY 2014
TRADE CONTROL POLICY FEBRUARY 2014 TRADE CONTROL POLICY 2 TABLE OF CONTENT 1 What is trade control? 3 2 What you should know 3 3 Who is affected? 4 4 What you should do 4 4.1 Know your deal items, customers
More informationGLOBAL TRADE & GOVERNMENT AFFAIRS. IT / Telecoms sector Risk management: sanctions compliance
GLOBAL TRADE & GOVERNMENT AFFAIRS IT / Telecoms sector Risk management: sanctions compliance In today's regulatory environment companies involved in cross-border activity have a clear and on-going requirement
More informationEvolving Legal Compliance Risks in Russia and Iran
Evolving Legal Compliance Risks in Russia and Iran David Lorello Covington & Burling LLP Breakbulk Europe, Antwerp, Belgium 14 May 2014 Overview Recent Developments in US and EU sanctions against Iran
More informationWhat You May Not Know About Sanctions (And How It Can Hurt You) by: Rajika Bhasin Counsel, Global Markets AIG
What You May Not Know About Sanctions (And How It Can Hurt You) by: Rajika Bhasin Counsel, Global Markets AIG What You May Not Know About Sanctions (And How It Can Hurt You) Introduction Companies navigating
More informationDIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011)
DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY (Adopted by resolution of the Board of Directors on December 1, 2011) Digital River, Inc. and our affiliates ( DR ) must comply
More informationAnti-Money Laundering and International Sanctions guidance for Coverholders
Anti-Money Laundering and International Sanctions guidance for Coverholders Introduction The purpose of this document is to provide general high-level guidance in relation to antimoney laundering ( AML
More informationFCPA and OFAC Compliance Essentials
OFAC FCPA and OFAC Compliance Essentials By The FCPA Report The DOJ, SEC and OFAC continue to put resources into enforcement of trade regulations and the FCPA, pursuing new investigative techniques and
More informationLATEST ON THE DODD-FRANK ACT AND INTERNATIONAL COMPLIANCE RISKS
Missouri Bar Annual Meeting, September 12, 2014 LATEST ON THE DODD-FRANK ACT AND INTERNATIONAL COMPLIANCE RISKS Presented by: Jennafer Watson, Chief Compliance Officer Layne Christensen Company Emmanuel
More informationForeign Corrupt Practices Act and Anti- Corruption Laws Compliance, Investigations, and Defense
Foreign Corrupt Practices Act and Anti- Corruption Laws Compliance, Investigations, and Defense Starting in 2007, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC)
More informationU.S. Export Controls E X T R A T E R R I T O R I A L I T Y - T H E L O N G A R M O F U. S. L A W. P e t e r W. K l e s t a d t M a y 8, 2 0 1 3
U.S. Export Controls E X T R A T E R R I T O R I A L I T Y - T H E L O N G A R M O F U. S. L A W P e t e r W. K l e s t a d t M a y 8, 2 0 1 3 U.S. EXPORT CONTROLS-EXTRATERRITORIALITY-THE LONG ARM OF U.S.
More informationFCPA and International Compliance
FCPA and International Compliance Briefing to San Antonio Post, SAME C. Ernest Edgar IV General Counsel, Atkins North America 1 Agenda Understanding the FCPA The Nuts and Bolts of the FCPA Who Is Covered
More informationThe ITAR and the FCPA: What You Disclose May Hurt You. October 7, 2014
The ITAR and the FCPA: What You Disclose May Hurt You October 7, 2014 Presenters Mark Srere Bryan Cave LLP Susan Kovarovics Bryan Cave LLP 2 Agenda Background on the FCPA Background on ITAR ITAR Part 129
More informationIntroduction To Commerce Department. Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES
Introduction To Commerce Department Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES Overview The Department of Commerce s Bureau of Industry and
More informationEXPORT CONTROLS COMPLIANCE
Responsible University Official: Vice President for Research Responsible Office: Office for Export Controls Compliance Origination Date: May 1, 2014 EXPORT CONTROLS COMPLIANCE Policy Statement Northwestern
More informationMastering Global Trade Compliance for Growth Through Export. Track 1 Session 3
Mastering Global Trade Compliance for Growth Through Export Track 1 Session 3 Julie Gibbs Director BPE Global Jgibbs@bpeglobal.com 415-595-8543 www.bpeglobal.com 2 Abstract It's not a small world after
More informationDevelopments in UE export controls. Jasper Helder, Baker & McKenzie Amsterdam 9 November 2012
Developments in UE export controls Jasper Helder, Baker & McKenzie Amsterdam 9 November 2012 How are EU Export Controls regulated? International EU National (EU Member State) International 2009 Baker &
More informationSanctions Update: North Korean Sanctions Toughened
Sanctions Update: North Korean Sanctions Toughened 24 March 2016 Background UN and US Sanctions were recently passed to condemn North Korea for its January 6 nuclear test and February 7 rocket launch.
More informationHOW GOVERNMENT SANCTIONS AFFECT YOUR GLOBAL PROGRAM (TLT024)
HOW GOVERNMENT SANCTIONS AFFECT YOUR GLOBAL PROGRAM (TLT024) Speakers: Valerie Joseph, Senior Vice President - International, Willis NA Tanja Maffei, Senior Vice President International, Willis NA Learning
More informationCorporate Code of Conduct
Corporate Code of Conduct Statement of Policy. It is the policy of Casa Mining Limited (the "Company") that all of its officers, directors, employees, contractors, consultants and agents representing the
More informationGetting aid to Syria
Getting aid to Syria Sanctions issues for banks and humanitarian agencies This paper is a collaborative effort by the British Bankers Association, the Disasters Emergency Committee and Freshfields Bruckhaus
More informationUS EXPORT CONTROLS & MARGARET M. GATTI, ESQ. LOUIS K. ROTHBERG, ESQ. FEBRUARY 23, 2012. www.morganlewis.com
US EXPORT CONTROLS & CLOUD COMPUTING MARGARET M. GATTI, ESQ. LOUIS K. ROTHBERG, ESQ. FEBRUARY 23, 2012 www.morganlewis.com WHAT IS CLOUD COMPUTING? Cloud Computing is a broad term with varied meanings
More informationAction Affecting Export Privileges; ANVIK TECHNOLOGIES SDN. BHD., a/k/a Anvik Technologies; BABAK JAFARPOUR, a/k/a BOB JEFFERSON
Billing Code: 3510-DT-P Department of Commerce Bureau of Industry and Security Action Affecting Export Privileges; ANVIK TECHNOLOGIES SDN. BHD., a/k/a Anvik Technologies; BABAK JAFARPOUR, a/k/a BOB JEFFERSON
More informationAnti-Bribery and Corruption Policy
Newcrest strictly prohibits bribery and other unlawful or improper payments made to any individual or entity, as outlined in this Anti-Bribery & Corruption Policy. Newcrest's Anti- Bribery & Corruption
More informationIntroduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts
Olga Torres, Associate Ol T A i t Braumiller Schulz LLP International Trade Law www.globaltradelaw.net Overview Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance
More informationRomanian Arms Export Control System. Legal framework
Romanian Arms Export Control System Legal framework Primary legislation Government Ordinance no. 158/1999 on the control regime of exports, imports and other transfers of military goods, approved with
More informationExport Control Training
2007 Export Control Training Office of Sponsored Research and Programs Missouri State University Missouri State University Research Security and Export Controls Compliance Manual 11/7/2007 1 As an employee
More informationERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011
ERIN ENERGY CORPORATION ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 Statement of Policy It is the policy of Erin Energy Corporation, (the Company ) to conduct its worldwide operations ethically
More informationKey Elements of International Trade Compliance. Presented by:
Key Elements of International Trade Compliance Presented by: International Business Transactions International Civil Litigation 2 I. Introduction Every international shipment implicates at least TWO legal
More informationDRAFT. Anti-Bribery and Anti-Corruption Policy. Introduction. Scope. 1. Definitions
DRAFT Change History: Anti-Bribery and Anti-Corruption Policy Control Risks Group Ltd Commercial in confidence Introduction This document defines Control Risks policy on the avoidance of bribery and corruption.
More informationIFA s 45 th Annual LEGAL SYMPOSIUM
LEGAL SYMPOSIUM The Foreign Corrupt Practices Act: What Every International Franchisor Must Know Moderator: Speakers: Eric L. Yaffe Gray Plant Mooty Washington, DC Mary C. Spearing Baker Botts L.L.P. Washington,
More informationExpanding Internationally with Confidence by Ensuring Global Trade Compliance
Expanding Internationally with Confidence by Ensuring Global Trade Compliance Justin Cook and Kendra Cook Canopy Consulting International (C2I) jcook@c2iconsulting.com / kcook@c2iconsulting.com www.c2iconsulting.com
More informationExport Controls: What are they? Why do we care?
Export Controls: What are they? Why do we care? Laura Langton, PhD Export Control Manager langton@wustl.edu 314-747-1378 http://research.wustl.edu/complianceareas/exportcontrols What is an Export? Release
More informationU.S. Department of Commerce Bureau of Industry and Security. How to Classify Your Item
U.S. Department of Commerce Bureau of Industry and Security How to Classify Your Item How is my Item Classified for Export Control Purposes? Commerce Control List ( CCL ) Export Control Classification
More informationIran Sanctions Relief and Further EU Regulatory Developments in 2016
January 2016 Practice Group: Antitrust, Competition & Trade Regulation Iran Sanctions Relief and Further EU Regulatory By Philip Torbøl, Raminta Dereskeviciute, Alessandro Di Mario and Daniel L. Clyne
More informationUniversity of Louisiana System
Policy Number: M-(16) University of Louisiana System Title: EXPORT CONTROL Effective Date: October 26, 2009 Cancellation: None Chapter: Miscellaneous Policy and Procedures Memorandum The University of
More informationFINANCIAL SANCTIONS: FREQUENTLY ASKED QUESTIONS
HM TREASURY FINANCIAL SANCTIONS: FREQUENTLY ASKED QUESTIONS (FAQs) August 2013 1 P age Contents 1 INTRODUCTION... 8 1.1 A note on publication arrangements... 9 2 UK Financial Sanctions a guide for beginners...
More informationANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
Issued: November 12, 2013 ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY SCOPE This policy applies to all Magnetek, Inc. ( Magnetek ) employees, its subsidiaries and affiliates worldwide,
More informationThe Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape
The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape Foreign Corrupt Practices Act: The Act What is the Act? Anti-Bribery Provisions Book and Record
More informationSupplier Code of Conduct. Ashland Inc. With good chemistry great things happen.
Supplier Code of Conduct Ashland Inc. With good chemistry great things happen. Our Vision What we seek to become. Our vision is to be viewed as the best specialty chemical company in the world. Our Mission
More informationSummary. Company A and B - Main Board listing applicants
HKEx LISTING DECISION HKEx-LD76-2013 (published in December 2013) Summary Name of Party Company A and B - Main Board listing applicants Subject Whether the Applicants were suitable for listing under Rule
More informationExport Controls and Cloud Computing: Legal Risks
Presenting a live 90-minute webinar with interactive Q&A Export Controls and Cloud Computing: Legal Risks Complying with ITAR, EAR and Sanctions Laws When Using Cloud Storage and Services TUESDAY, APRIL
More informationSanctions risk: what is the regulatory challenge for compliance officers?
Sanctions risk: what is the regulatory challenge for compliance officers? Nov 02 2012 Miriam Gonzalez, John Forrest and Chloe Barker Compliance with domestic and international sanctions regimes has become
More informationSEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy
SEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy General Policy: SEKO Logistics ( SEKO ) conducts its business ethically and in compliance with all laws in the countries where SEKO
More informationCERUS CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS
CERUS CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Introduction We are committed to maintaining the highest standards of business conduct and ethics. This Code of Business Conduct and Ethics reflects
More informationMinerals Technologies Inc. Summary of Policies on Business Conduct
Minerals Technologies Inc. Summary of Policies on Business Conduct Lawful and Ethical Behavior is Required at All Times This Summary of Policies on Business Conduct (this "Summary") provides an overview
More informationMATTHEWS INTERNATIONAL CORPORATION
MATTHEWS INTERNATIONAL CORPORATION U.S. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY INTRODUCTION Principles Underlying the United States Foreign Corrupt Practices Act ( FCPA ). The FCPA s Anti-Bribery
More informationANTI-CORRUPTION AND ANTI-BRIBERY POLICY
COMPLIANCE 18.0 ANTI-CORRUPTION AND ANTI-BRIBERY POLICY I. SCOPE This policy applies to all directors, officers, employees, agents, and shareholders of UHS of Delaware, Inc. (hereafter, UHS ), its subsidiaries
More informationcompany policy number 0001 LEGAL AND ETHICAL CONDUCT
company policy number 0001 LEGAL AND ETHICAL CONDUCT eff. date replaces page 28 Mar. 2011 14 Feb. 2006 1 of 10 PURPOSE CPI has adopted this Code of Legal and Ethical Conduct ( Code ) to promote: honest
More informationUnited States Export Controls on Internet Software Transactions. John F. McKenzie Partner, Baker & McKenzie LLP
United States Export Controls on Internet Software Transactions John F. McKenzie Partner, Baker & McKenzie LLP August 2010 Table of Contents 1. Introduction...1 2. The Concept of an "Export" for Export
More informationPHILIP H. HILDER H I L D E R A N D A S S O C I A T E S, P. C. 8 1 9 L O V E T T B L V D. H O U S T O N, T E X A S 7 7 0 0 6 7 1 3-6 5 5-9 1 1 1 W W W
FCPA Now and Later PHILIP H. HILDER H I L D E R A N D A S S O C I A T E S, P. C. 8 1 9 L O V E T T B L V D. H O U S T O N, T E X A S 7 7 0 0 6 7 1 3-6 5 5-9 1 1 1 W W W. H I L D E R L A W. C O M Purpose
More informationEnforcement Program and the New Whistleblower Rules. June 16, 2011
The FCPA,, the SEC s Revamped Enforcement Program and the New Whistleblower Rules June 16, 2011 Today's Presenters Paul Huey-Burns Therese D. Pritchard Mark Srere 2 Topics for Discussion FCPA Enforcement:
More informationRecent FCPA Enforcement Activities
November 2006 Recent FCPA Enforcement Activities By William F. Pendergast, Matthew R. Fowler and Jennifer D. Riddle This client alert provides a synopsis of recent Foreign Corrupt Practices Act ( FCPA
More informationExport Control Laws Training Presentation FLORIDA INSTITUTE OF TECHNOLOGY
Export Control Laws Training Presentation FLORIDA INSTITUTE OF TECHNOLOGY 1 Why Be Concerned with Export Control Laws Certain export control laws may apply to FIT research activities here and abroad. Failure
More informationHow To Know If You Can Get A Job At A Company
What Maritime Lawyers Need to Know about the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws? Presented by Evelyn M. Suarez & Jim Barratt 2015 Port Administration & Legal Issues Seminar
More informationAdministrative Policy No. AD 2.26 Title:
I. SCOPE: Administrative Policy No. AD 2.26 Page: 1 of 5 This policy applies to all directors, officers, employees, agents, and shareholders of Tenet Healthcare Corporation, its subsidiaries and/or affiliates
More informationCounterterrorism and Humanitarian Engagement Project
Counterterrorism and Humanitarian Engagement Project OFAC Licensing Background Briefing March 2013 I. Introduction 1 The U.S. Department of Treasury s Office of Foreign Assets Control (OFAC) administers
More informationAPEC General Elements of Effective Voluntary Corporate Compliance Programs
2014/CSOM/041 Agenda Item: 3 APEC General Elements of Effective Voluntary Corporate Compliance Programs Purpose: Consideration Submitted by: United States Concluding Senior Officials Meeting Beijing, China
More information2374-19. Joint ICTP-IAEA School of Nuclear Energy Management. 5-23 November 2012. Nuclear Security Fundamentals Module 9 topic 2
2374-19 Joint ICTP-IAEA School of Nuclear Energy Management 5-23 November 2012 Nuclear Security Fundamentals Module 9 topic 2 EVANS Rhonda, IAEA Department of Nuclear Safety and Security Office of Nuclear
More informationPolicy. Practice. Scheduled Trading Blackouts. May 13, 2015
May 13, 2015 Policy To promote compliance with insider trading prohibitions and to avoid any perception that the Company's insiders have engaged in any improper trading, its directors; officers; those
More informationTop 10 Questions to Ask Before Exporting Software Containing Encryption
Top 10 Questions to Ask Before Exporting Software Containing Encryption January 14, 2009 Agenda Introduction FOSSBazaar Top Ten Questions Before Exporting Encryption Questions & Answers Speakers Eran Strod
More informationPolicy Title: INSIDER TRADING POLICY # of Pages - 10. Approval Source: Board of Directors
GIBSON ENERGY (and affiliated companies) POLICY Department Responsible: Legal Policy # CORP 6.0 Policy Title: INSIDER TRADING POLICY # of Pages - 10 Initial Approval Date: August 10, 2011 Revision #: 2
More informationCC255 C O R P O R A T E. Altus FCPA Policy. Last revised: 12 October 2010
CC255 Altus FCPA Policy Last revised: 12 October 2010 C O R P O R A T E Foreign Corrupt Practices Act Policy Purpose The purpose of this Policy is to ensure compliance by Altus and its directors, officers,
More informationInca One Gold Corp. Insider Trading Policy
Inca One Gold Corp. Insider Trading Policy 1.0 Introduction The Board of Directors (the Board ) of Inca One Gold Corp. ( Inca One ) 1 has determined that Inca One should formalize its policy on securities
More informationWorldwide Anti-Corruption Policy
Worldwide Anti-Corruption Policy I. PURPOSE The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both Eaton
More informationA Primer on U.S. Export Controls
A Primer on U.S. Export Controls Presentation for the Pacific Northwest Defense Coalition By Akana K.J. Ma Partner, Ater Wynne LLP 16 July 2013 (503) 226-8489/akm@aterwynne.com Akana K.J. Ma 2013 All Rights
More informationComplying with the U.S. Foreign Corrupt Practices Act
Complying with the U.S. Foreign Corrupt Practices Act 1. About This Manual This Manual describes the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C. 78m, 78dd, 78ff (collectively, FCPA ), anti-corruption
More informationExport Control Compliance Procedure Guide June 8, 2012
Export Control Compliance Procedure Guide June 8, 2012 1 TABLE OF CONTENTS Contents TABLE OF CONTENTS... 1 SUMMARY... 2 INTRODUCTION... 3 SCHOOL POLICY... 4 EXCLUSIONS... 4 WHAT IS AN EXPORT?... 4 CONDUCTING
More informationRegulatory Compliance and Trade
Regulatory Compliance and Trade Global Transaction Services Cash Management Trade Services and Finance Securities Services Fund Services Regulatory Compliance and Trade 2007 These materials are provided
More informationRegulation for Compliance with Anti-Corruption Acts
Regulation for Compliance with Anti-Corruption Acts 2014. 2. 24. Samsung Techwin Co., Ltd. Table of Contents Chapter 1 Article 1 Article 2 Article 3 General Rules Purpose Applicability Definition Chapter
More informationTECHNOLOGY CHECKLIST FOR COMPANY MANAGERS AND COUNSEL
TECHNOLOGY CHECKLIST FOR COMPANY MANAGERS AND COUNSEL 2009 WilmerHale LLP Table of Contents I. Inventory of Intellectual Property Assets...1 A. Patents... 1 B. Trademarks/service marks... 1 C. Common law
More informationCredit Investigations and Getting to Know Your Customer. Speaker Ed Bell, PhD, CICP, ICCE Date June 13 th, 2016 Time 3:45 5:00pm Session Number 25030
Credit Investigations and Getting to Know Your Customer Speaker Ed Bell, PhD, CICP, ICCE Date June 13 th, 2016 Time 3:45 5:00pm Session Number 25030 Going Global Series Credit Investigations and Getting
More informationRisk Factors for OFAC Compliance in the Securities Industry
Risk Factors for OFAC Compliance in the Securities Industry Updated November 5, 2008 Introduction The U.S. Department of the Treasury s Office of Foreign Assets Control ( OFAC ) is charged with administering
More informationPrivacy Law in Canada
Privacy Law in Canada Federal and provincial privacy legislation has a profound impact on the way virtually all organizations carry on business across the country. Canada s privacy laws, while likely the
More informationEXPORT CONTROLS AND RESEARCH AT WPI TRAINING PRESENTATION
EXPORT CONTROLS AND RESEARCH AT WPI TRAINING PRESENTATION EXPORT CONTROL LAWS WHAT ARE EXPORT CONTROLS? U.S. laws and their implementing regulations that govern the distribution to foreign nationals and
More informationSecurity Export Control System in Japan. Ministry of Economy, Trade and Industry, Japan http://www.meti.go.jp/policy/anpo/index.
Security Export Control System in Japan Ministry of Economy, Trade and Industry, Japan http://www.meti.go.jp/policy/anpo/index.html 2009 1-1 Legislation-List Control and Catch-all Control The Foreign Exchange
More informationImplementing Catch All Controls A Risk Assessment-based Approach Toward Nonproliferation
Implementing Catch All Controls A Risk Assessment-based Approach Toward Nonproliferation Mr. Dennis Krepp Office of National Security and Technology Transfer Controls U.S. Department of Commerce March
More informationINSURANCE AGENT AND BROKER COMPLIANCE WITH THE PATRIOT ACT ANTI-MONEY LAUNDERING REQUIREMENTS AND OFFICE OF FOREIGN ASSETS CONTROL REGULATIONS
INSURANCE AGENT AND BROKER COMPLIANCE WITH THE PATRIOT ACT ANTI-MONEY LAUNDERING REQUIREMENTS AND OFFICE OF FOREIGN ASSETS CONTROL REGULATIONS This FAQ is not intended to provide specific advice about
More informationBUSINESS PRINCIPLES FOR COUNTERING BRIBERY A MULTI-STAKEHOLDER INITIATIVE LED BY TRANSPARENCY INTERNATIONAL
BUSINESS PRINCIPLES FOR COUNTERING BRIBERY A MULTI-STAKEHOLDER INITIATIVE LED BY TRANSPARENCY INTERNATIONAL Transparency International is the global civil society organisation leading the fight against
More informationAnti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals
Anti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals LeClairRyan Carlos F. Ortiz 973.491.3365 carlos.ortiz@leclairryan.com Valerie C. Charles
More informationBELIZE INTERNATIONAL FINANCIAL SERVICES COMMISSION STANDARD CONDITIONS FOR A SECURITIES TRADING LICENCE
BELIZE INTERNATIONAL FINANCIAL SERVICES COMMISSION STANDARD CONDITIONS FOR A SECURITIES TRADING LICENCE This License is issued subject to the following conditions:- 1. The Licensee shall at all times comply
More informationLion One Metals Ltd. Insider Trading Policy
Lion One Metals Ltd. Insider Trading Policy 1.0 Introduction The Board of Directors of Lion One Metals Ltd. ( Lion One ) 1 has determined that Lion One should formalize its policy on securities trading
More informationSimplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance
Simplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance Arm Stakeholders with Critical Information to Assess 3rd Party Relationships and Comply with the Foreign Corrupt Practices Act
More information